Navigating PFAS Substitution: Practical Insights and Industry Perspectives

Directors of the European Commission’s Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) and the Directorate General for Environment (DG ENV) opened FPP4EU’s Collaboration Platform on 20 January 2026 by underscoring that action on PFAS is essential to protect human health and the environment. At the same time, they acknowledged the need to strike a careful balance to avoid jeopardising uses that are critical to strategic autonomy and green transition objectives, especially where no viable alternatives have yet been established. To support companies in the process of finding alternatives, the Commission is working to establish a network of EU innovation and substitution hubs.

The aim of the event was to provide a platform for downstream users and chemical companies to exchange practical insights and industry perspectives on PFAS substitution, under strict compliance with competition law.

Downstream Users: Complex Needs, Interconnected Systems

Presentations from the medical, automotive, and aviation/defense sectors illustrated that PFAS substitution is highly complex because these industries rely on multiple, highly specialised uses of PFAS integrated deeply within interconnected systems. PFAS-containing materials and components are embedded across thousands of parts—ranging from an aircraft’s certified safety critical systems to the 18,000 components that make up a vehicle – each of which must meet strict standards for durability, chemical and heat resistance, and reliability, among others. In the medical sector ‘biocompatibility’ is added to that list.

These components are sourced from numerous suppliers, creating long, multitiered value chains, meaning that altering even one material can trigger cascading redesign, testing, and validation steps across multiple suppliers. The medical sector reports thorough testing of alternative candidate materials with performance failures, such as on durability, chemical/thermal resistance, corrosion, residues, friction, contamination risk, etc.

The actual process of substituting even one of these materials first requires suppliers to develop candidate substances. Only then can the testing process start. Even once a candidate material exists, the validation pathway is long and sequential: feasibility screening, component level qualification, system level integration, and final signoff. Failure at any gate forces a return to earlier design stages, adding years to programmes and pushing changes across multitier supply chains.

In aviation, technical bodies must certify every modification to ensure flight safety, and in defense, equipment must remain deployable and reliable under all conditions—constraints that make rapid substitution unrealistic. Additionally, both sectors must ensure long-term availability of spare parts—often for a decade or more—further complicating an abrupt shift away from PFAS.

Upstream Suppliers: Innovation Challenges and Validation Barriers

One chemical supplier highlighted the difficulty of meeting the diverse validation requirements of downstream users. An alternative that works for one customer may not meet the performance needs of another, given the wide range of technical specifications and operating environments. This diversity, combined with long development and testing cycles, makes establishing a clear business case for substitution challenging.

Conclusion: Substitution cannot be scheduled on a fixed calendar

There is currently a mismatch between regulatory timelines and industrial development cycles, as well as the strict validation requirements that govern these sectors.

These shared challenges highlight the need for regulatory understanding, realistic transition timelines, and partnerships across the entire supply chain. Only through joint efforts can overall trends in PFAS substitution progress without compromising safety, performance, or strategic preparedness.